Lecture 7

I started the lecture with a recap of what we had learnt about ISO-14001; scope, policy, aspects & impacts, objectives, targets & programmes. . We proceeded to discuss the various sub-sections under 4.4 - Implementation (DO). This section has seven sub-sections, viz., 4.4.1 - Resources, Roles, Responsibilities and Authority, 4.4.2 - Competence, training and awareness, 4.4.3 - Communication, 4.4.4 - Documentation, 4.4.5 - Control of documents, 4.4.6 - Operational Control and 4.4.7 - Emergency Preparedness and Response.

4.4.1 - Resources are to be provided by the management for establishing, implementing and maintaining the Environmental Management System - these resources are human resources, financial resources, infrastructure and information. The top management has to appoint a Management Representative to establish, implement and maintain an Environmental Management System and to report to the management periodically about the effectiveness of the system. Role is the part played by employees apart from the functions for which they are responsible or results for which they are accountable to. An employee, for example an Accounts Officer, may take the role of an internal auditor or a trainer even though his main responsibility is in Accounting. ( We discussed the ROLE played by individual in real life - a man is a husband to his wife, is a brother to his sister or brother, is a son to his parents, is a friend to his friends etc. These are various roles he plays in his life). In order to ensure that the system is effective the management should document the responsibilities and authority (to take actions, decisions etc.) and make it known to all concerned employees.

4.4.2 - Competence of employees who are responsible for activities related to identified significant aspects need to be ensured; competence is related to qualification, training and experience. ALL employees have to be trained to understand the policy, procedures and other relevant elements of the EMS. ALL is the key word here. We discussed the case of a CEO who had not been trained in the emergency procedure and response; how would he come to know about the emergency and save his life in case of an actual emergency ?

4.4.3 - Communication is of two types, (a) internal communication with employees and contract workers working within the premises and (b) external communication with stakeholders outside the organization, like the Government Departments, Statutory bodies, NGOs, Banks, Neighbours etc. Procedure for both internal and external communication should be effective (e.g. the internal communication should ensure that the receipient of the communication has understood the content of the communication). The procedure for external communication should address the receipt and response to communication from external stakeholders. The organization should decide whether to communicate its significant environmental aspects to external stakeholders and record its decision. One method of external communication is the Global Reporting Initiative (GRI) guideline based Sustainability Reports.

4.4.4 - Documentation - Information with its supporting medium (paper, magnetic tape, CD, DVD etc.) is a document; Records are a sub-set of documents. Procedures, Policy, Objectives/targets/programmes etc., with the medium on which they are captured are documents. Information on the past activity, including measurements, reviews etc., are RECORDS. While documents, except RECORDS, could be changed, RECORDS cannot be changed/altered. Documents, including Records, are used as evidence of the working of the Environmental Management System. Environmental Management System Manual, capturing various elements of the EMS is one such document (ISO-14001 does not prescribe a written manual, but for better working of the system a written manual is recommended)

4.4.5 - Documents are controlled; that means that the documents are checked for their authenticity and are verified and approved by those authrorized to issue documents. This procedure is necessary to avoid obsolete documents being used in the organization. Current documents need to be available at the all places where related work is carried out. Control is also required for documents which have external origin (e.g. standards, legal documents etc). We discussed how a part of the organization was not meeting the requirement of law as they were using obsolete standards for emissions and how this could lead to risk to the organization.

4.4.6 - We discussed issues related to operational control procedures that are established to address significant environmental aspects, Procedures have to established for those activities which can cause environmental impact. These procedures identify the scope, responsibility, and the "how" of doing things.

These procedures also apply to contractors and suppliers where relevant. Procedures need not be just a summary of what has to be done; they can also presented in the form of flow-charts for clarity. Procedures should also identify the "operational Criteria" - operational ciriterion is that indicator which provides information for action that reduces the environmental impact.

4.4.7 - We discussed issues related to emergency/accident procedures and the consequence of the procedure. Incidents are indications of what is expected in days to come. Accidents and their analysis for prevention will help an organization Environmental emergency situations are those where the surrounding populations have to be evacuated or the emissions/dicharges can pollute the ground water around.. One needs to take precautions while using emergency measuers; they should not lead to other environmental issues (e.g. Sandoz fire in Switzerland

CHECK

4.5. Once we plan and implement, the next step is to CHECK. There are Five sub-sections under Checking, viz., 4.5.1 - Monitoring and Measurement, 4.5.2 - Evaluating Compliance (4.5.2.1 - Evaluation of Legal Compliance and 4.5.2.2 - Evaluation of other compliance), 4.5.3 - Non-conformity, corrective action and preventive action, 4.5.4 - Control of Records and 4.5.5 - Internal Audits

4.5.1 All environmental management programmes have to be monitored; where required measurements have to be made on identified parameters. The equipments used for such measurements have to be calibrated and the calibration records have to be maintained

4.5.2 - Procedures have to be established and implemented to periodically evaluate compliance with legal requirements as well as with other requirements to which the organization subscribes. The results of these evaluation have to be documented. In case of non-conformance, corrective and preventive actions have to be in place.

4.5.3 - Once a non-conformance to any element of the system requirements is noticed, corrective and preventive actions have to be taken to eliminate or avoid the recurrence of the non-conformance. A corrective action is the removal of the cause of non-conformance identified so that the non-conformance does not recur. The preventive actions is the change effected to the system to avoid the potential non-conformance. Preventive action is, therefore, a proactive action.

4.5.4 - In order to provide evidence that the system is working the orgnization should maintain records like the training record, record of audits and minutes of the Management Review etc. The organization decides as to which of the records are required to demonstrate the working of the environmental management system.

4.5.5 - Internal audits are carried out to evaluate the working of the EMS. Internal audits may be carried out by competent persons from within the orgnization or by those working outside the organization. An EMS audit is a systematic process of objectively collecting audit evidence against audit criteria, evaluate the audit evidence, to conclude if there sufficient evidence to show if the EMS audit criteria are met and to report to the client the conclusion of the findings. EMS internal audits have to be carried out according to ISO-19011: Guidelines for Quality and/or Environmental Management System Auditing.

4.6 Once the elements of Checking have been established and implemented, the next step to go for the Management Review. The management review addresses issues like a) results of internal audits and evaluations of compliance with legal requirements and with other requirements to which the organization subscribes, b) communication(s) from external interested parties, including complaints, c) the environmental performance of the organization, d) the extent to which objectives and targets have been met, e) status of corrective and preventive actions, f) follow-up actions from previous management reviews, g) changing circumstances, including developments in legal and other requirements related to its environmental aspects, and
h) recommendations for improvement.

The output of the management review includes, decisions and actions related to the possible changes to environmental policy, objectives, targets and other elements of the environmental management system, consistent with the commitment to continual improvement. The discussions and decisions taken at the Management Review are minuted.

Thus the Management Review completes one PDCA cycle of the EMS and triggers off the next PDCA Cycle for improving the organization's environmental performance.